OAR Box 1669 

Prepped by Charmelle Mathews 

Document Number: 

jtf j€j ll-E-8 

Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 76 of 110 

P.1 
£FH3£ 

O 

MEMORANDUM 

A 9813 ^ 

P.2 

TO: Project File 

Organic Liquids Distribution NESHAP 

ESD Project No. 96/05 

FROM: Bernd Haneke^A-r 

Pacific Environmental Services, Inc. 

DATE: August 13,1998 

P :\n812\meetings\icrmem. wpd 

i a-p-1 ; 

I. 

F.PAAir-! JOOKl-iT 

*""*l 

SUBJECT: Minutes ofthe Information Collection Request Workshop in Houston, Texas 

I. Purpose 

The purpose ofthis meeting was to provide industry representatives with a forum to ask 

the EPA project team questions regarding the proper ways to respond to the information 

collection request (ICR) for the organic liquids distribution (OLD) industry. In turn, the 

workshop provided the EPA project team with an opportunity to identify and address problem 

areas within the ICR. 

II. Location 

Exxon Company U.S.A. 

Bell Street Conference Center 

800 Bell Street-Room C-101 

Houston, Texas 77002 

June 3, 1998 (9:00 am -1:45 pm) 

III. Participants 

Industry Representatives 

See Attachment 1 

U.S. Environmental Protection Agency 

Steve Shedd - OAQPS/ESD/WCPG, Research Triangle Park, NC 

Pacific Environmental Services. Inc. 

Bernd Haneke - RTP, NC 

Greg LaFlam - RTP, NC 
P.3 

ICR Workshop Memo 

August 13,1998 

Page 2 

IV. Workshop Agenda 

Time 

9:00-9:15 

9:15-10:20 

10:20-10:35 

10:35 -10:45 

10:45-11:40 

11:40-12:30 

12:30-1:45 

Presenter 

Chuck Feerick, Bill Beck, Steve Shedd 

Greg LaFlam 

Break 

Greg LaFlam 

Bernd Haneke 

Lunch 

Steve Shedd, Greg LaFlam, Bernd Haneke 

V. Workshop Summary 

ICR Instructions 

Chuck Feerick opened the workshop by explaining the facilities and safety procedures at 

the Bell Street Conference Center. Next, Bill Beck gave a brief introduction to the MACT 

process and the joint industry /EPA development ofthe ICR. 

Bill Beck was followed by Steve Shedd, who briefly discussed the Clean Air Act, 

NESHAP development, and the purpose ofthe ICR workshop. Mr. Shedd also told workshop 

attendees that the deadline for responding to the ICR had been extended to August 3,1998, upon 

which numerous persons inquired whether extensions beyond that time period would be 

available. Mr. Shedd indicated that this was not likely to be the case. 

Following Mr. Shedd's brief introduction, Greg LaFlam began presenting and explaining 

an outline ofthe ICR instructions. Overhead slides (Attachment 2) were used to maintain the 

logical flow and consistency ofthe presentation. A question and answer period was provided at 

logical break points during the presentation, and issues brought up during these sessions are 

discussed in this document. 

Mr. LaFlam presented slides 1 through 7, and then stopped for a brief question and 

answer period. One attendee asked if it would be appropriate to submit table 2 ofthe ICR as a 

Microsoft Excel file, due to the fact that the infonnation requested was available in that format. 

The EPA Project Team indicated that would be appropriate, as long as all information requested 

in the official survey's table was provided. Another attendee commented that the electronic ICR 

was only a WordPerfect or Adobe file, and that converting it to MS Word had changed the 

format substantially. Mr. Haneke explained that converting files from WordPerfect to MS Word 

could change the formatting, but that it should not be difficult to rectify this situation. One 

person inquired as to the origin ofthe ICR's hazardous air pollutant (HAP) list, to which the 

EPA project team responded that it is officially from 40 CFR 63.2. It was noted that there had 

V 
P.4 

ICR Workshop Memo 

August 13,1998 

Page 3 

been changes made to the HAP list over time, to which the EPA project team responded that the 

latest official version ofthe HAP list should be used. The final question was in regard to the 

inclusion or exclusion of inorganic HAP in liquids. Mr. Shedd responded that this survey only 

takes into account organic HAP. 

Following the question and answer session, slides 8 through 11 were presented by Mr. 

LaFlam. These slides addressed such issues as plant emissions, distribution operations, and 

examples of organic liquids distribution facility types. A workshop participant asked if 

emissions estimates should be based upon actual emissions or potential-to-emit (PTE), upon 

which the EPA project team informed the participant that all estimates should be based upon 

actual emissions. Another participant asked if control equipment should be factored into the 

actual emissions estimates, to which the project team answered that the estimates should be 

"after controls", and that all control equipment (unless dedicated for use under another MACT 

rule) should be described in Table 9 ofthe ICR package. One participant asked if reactor vessels 

should be included under compounding operations. The EPA project team replied that reactor 

vessels are a process and not part ofthe distribution process, and would therefore not have to be 

covered in the survey. 

Mr. LaFlam then proceeded to present slides 12 through 14 in which issues such as 

organic liquids to be surveyed, waste and wastewater to be surveyed, and non-surveyed liquids 

were discussed. A brief discussion ensued regarding the 0.5 million gallon per year wastewater 

cutoff. One attendee asked if that cutoff pertained to all wastewater at a facility, or only to that 

portion belonging to OLD. The EPA project team response was that all wastewater at a plant 

site was to count toward the 0.5 million gallon cutoff, but only the wastewater from the OLD 

facility would have to be quantified in the tables. Another participant inquired as to which 

measure of vapor pressure was to be used in the applicability determinations, to which the EPA 

project team replied that true vapor pressure (tvp) is the appropriate parameter. 

Slides 15-19 were presented next by Mr. LaFlam. These slides discussed the 

applicability of various MACT standards, including the Marine Vessel Operations MACT, the 

Hazardous Organic NESHAP, and the Refinery MACT. Numerous questions were brought up as 

a result of these slides, and many of these are discussed in Attachment 3. Some ofthe major 

issues included a discussion about the term "distribution", and whether liquefied gases should be 

included in the survey. It was also asked if unloading operations are pertinent to this ICR, due to 

the fact that unloading does not generate emissions. Mr. Shedd responded that an immediate 

answer to this was not available, but a decision would be made promptly. 

After a coffee break, Mr. LaFlam proceeded to present slides 20-21, in which such issues 

as MACT standards that had not been promulgated, as well as MACT standards that were not 

discussed in slides 15 through 19 were discussed. Mr. LaFlam also briefly discussed what 

information would have to be submitted for operations and equipment covered under other final 

3 
P.5 

ICR Workshop Memo 

August 13,1998 

Page 4 

or non-final MACT standards. Numerous participants commented that creating a plot plan 

showing non-OLD operations would entail many hours of work, and would provide only limited 

information. A brief discussion ensued as to the level of detail required for the plot plans, and 

Mr. Shedd noted that a detailed sketch would suffice. The EPA project team noted that this 

information is required to enable the team to understand the entire facility and to gain knowledge 

about operations in the organic liquids distribution industry. 

Issues pertaining to gasoline and gasoline operations at surveyed facilities were discussed 

by Mr. LaFlam in slides 22-24. It was noted that gasoline transfers that serve to refuel vehicles 

or equipment within the plant site should not be reported in the survey response. Some 

participants commented that they considered this to be inappropriate as gasoline transfers could 

be considered to be organic liquid distribution operations. 

ICR Tables 

Following Mr. LaFlam's presentation ofthe ICR instructions, Mr. Haneke began a 

discussion ofthe individual tables within the ICR. Mr. Haneke presented overhead 

transparencies ofthe tables, discussed the required information for each table, and then answered 

questions (jointly with Greg LaFlam and Steve Shedd) regarding each table from the workshop 

participants. 

Following the brief discussion of Table 1, numerous participants raised issues regarding 

the surveyed liquids. Some participants questioned the applicability ofthe required data, stating 

that it would not be necessary or pertinent in many cases. The EPA project team responded that 

the best available information should be supplied, and that in most cases the information would 

be necessary to calculate emissions. Furthermore, the team added, most ofthis information was 

necessary as the TANKS3.1 program only includes a small subset of organic liquids, and the 

requested information would be needed for emissions calculations. One participant noted that 

Reid vapor pressure (RVP) would only be available for certain petroleum products, to which the 

EPA project team responded that the survey had been designed with numerous liquid types in 

mind, and therefore certain parameters may be inapplicable for some respondents. 

Tables 2 and 3 did not generate substantial questions, and so a detailed discussion is not 

included in this memorandum. Numerous questions were asked regarding Tables 4 and 5 

(Wastewater Flow and Drain Control, Wastewater Collection and Treatment). One participant 

asked if the principal sources of wastewater generation would only have to include those from 

the OLD portion of a facility. The EPA project team affirmed this conclusion. One participant 

inquired as to the definition of a drain, to which the project team refened the person to the 

language ofthe Hazardous Organic NESHAP (HON). 

A workshop participant noted that the Resource Conservation and Recovery Act (RCRA) 

H 
P.6 

ICR Workshop Memo 

August 13,1998 

Page 5 

was going to cover most ofthe sludges produced (refer to Table 6) at facilities, and that the EPA 

project team would therefore not need this information. The EPA project team responded by 

acknowledging this fact, and replied that sludges regulated by RCRA should not be reported in 

the survey. 

Equipment leak information was presented and discussed as it pertains to Table 7. A 

participant inquired whether a leak detection and repair (LDAR) program had to be prescribed by 

a formal regulation in order to be addressed in this table. Mr. Shedd responded that a formal 

program would be required to trigger the applicability ofthe table. 

In Table 8, Mr. Haneke reiterated the fact that infonnation on the families of blends 

would be acceptable, thereby reducing the volume of information returned in the survey. Mr. 

Haneke also stated that the EPA wanted concise, 2 to 3 paragraph responses for Part II of Table 

8. 

No comments or questions were asked about Table 9 (Air Pollution Control Equipment 

Parameters). The project team mentioned that the tables should be filled out with the best 

available information, and that if a piece of essential control equipment was not included in the 

survey, the respondent should fill out a table similar to the ones presented. 

Question and Answer Session 

The EPA project team requested that participants place extra questions on index cards so 

that they could be addressed during this part ofthe workshop. A number ofthe cards (but not 

all) received were read and responded to during this session. Questions generated by answering 

the cards were also fielded. Attachment 3 provides a summary ofthe issues and questions 

brought up during the first part ofthe workshop, and during the final question and answer 

session. 

VI. Conclusion 

Following the question and answer session, the EPA project team indicated that the EPA 

would be posting some ofthe principal and most frequently asked issues and questions, along 

with the EPA's answers and comments, on the TTN website. Following some concluding 

remarks, the project team thanked the workshop attendees for their time and participation, and 

the meeting was adjourned. 

5 
P.7 

ATTACHMENT 1 

6 
P.8 

Attendance Roster for the Joint EPA & Industry Workshop on the Information CoUection 

Request for the Organic Liquids Distribution (non-Gasoline) Industry—June 3,1998 

Exxon Conference Center-800 Bell Street, Houston, TX 

Name of Attendee 

Don Mark Anthony 

Jordan Jacobsen 

Alice Boomhower 

Bob Hermanson 

Tim Weisenberger 

JudyMundt 

Miriam Lev-On 

Denise Michelson 

Ed J. Bergman 

Paul Hunt 

Richard Langford 

Roger Tower 

Robert C. Walker 

Dave Monfore 

George H. Gott 

Robert A. Morris 

Terry Soule 

Dan Rhine 

Joe Ledvina 

Milind J. Bhatte 

W.L. Wamement, Sr. 

Ed Guirovich 

Ben Strange 

Bmce Alexius 

Liane Platt 

Toby Threet 

Vance Dan* 

Emily Montgomery 

Thomas Jackson 

Sharon Hampton 

Jim Schlembach 

Brian Magruder 

Chuck Feerick 

Rowland Ivy 

Norman Morrow 

Rochelle M. Jozwiak 

Mike Innerarity 

Mark Pike 

Mike McWilliams 

G.C. Shah 

Company 

Alyeska Pipeline 

Alyeska Pipeline 

Amoco 

Amoco Corp 

Amoco 

Amoco 

ARCO 

ARCO Pipe Line 

BASF Corp. 

Celanese Engineering Resins, Inc. 

Celanese Acetate 

Celanese 

Chevron 

Citgo 

Citgo Petroleum 

The Coastal Corp. 

Coastal Refining 

Coastal Refining 

CONDEA Vista Co. 

Conoco 

Crown Central Pet 

Delta Terminal Services 

Delta Terminal Services 

Dow Chemical Company 

Dow Chemical Company 

Dow Chemical Company 

Eastman Chemical Co. 

Eastman Chemical 

Equilon Enterprise LLC 

ERM-Southwest 

Exxon 

Exxon Pipeline 

Exxon 

Exxon 

Exxon Chem. Amer. 

Exxon Chemical 

Exxon 

Exxon Pipeline 

Exxon 

Fina Oil and Chemical 

Email 

jacobsenje@alyeska-pipeline.com 

aeboomhower@amoco.com 

rwhermanson@amoco.com 

timouiyJ_weisenberger@amoco.com 

jrmundt@amoco.com 

mlevon@mail.arco.com 

ztcdcm@mail.arco.com 

bergmaej@basf-corp.com 

whunt@bishopfacility.com 

rlangfor@wpo.acc.com 

ret@clkhccl.hcc.com 

rcwa@chevron.com 

dmonfor@citgo.com 

geogott@citgo.com 

robeit.morris@coastaIcoip.com 

teny.soule@coastalcorp.com 

dan.rhine@coastalcorp.com 

jledvina@cvc.net com 

milind.j.bhatte@usa.conoco.cora 

williamw33@aol.com 

balexius@dow.com 

lmplatt@dow.com 

vrdarr@eastman.com 

emont@eastman.com 

jacksth@texaco.com 

jim.schlembach@exxon.sprintcom 

chuck.p.feerick@exxon.com 

rowland.d.ivy.exxon.sprint.com 

nonnanl.morrow@exxon.sprint com 

rochelle.m.jozwiak@exxon.sprintcom 

mikal.s.innerarity@exxon.sprintcom 

mark.c.pike@exxon.sprintcom 

mike.s.mcwilliams@exxon.sprint.com 

£.c.shah(2)fina.com 

1 
P.9 

Organic Liquids Distribution (non-gasoline) ICR Workshop Attendance Roster 

Name of Attendee 

Pradeep Shetty 

Mary Logue 

Kevin Bloomer 

Ushra Mehra 

Stephen V. Capone 

Lon Tullos 

Joel Fazzio 

Gina Christian 

Jim Sebastian 

Dale Rhoades 

Barbara Castleberry 

Gary Wilson 

William G. Moore 

Dave Elder 

Kathleen Bowden 

Laura Ann Dresser 

Justin Stubbe 

Bill Beck 

Thomas Land 

Stephen S. Tucker 

Scott Hartman 

Dan Gresham 

John M. Edgington 

D.T. Emery 

Steven R. Hansen 

Paul Zawila 

Lee Netterville 

Jack Coblenz 

Charles F. Hamilton 

Odessa R. Marshall 

Rebecca Demeter 

Craig Allison 

Hal Taback 

John Nesser 

Marten Mosts 

Allan A. Griggs 

Dana Neely 

1 Don Wan" 

Company 

Fina Oil & Chemical 

Fina Oil and Chemical Company 

FINA Oil & Chemical 

GATX 

GE Plastics 

Huntsman Petrochem. 

lMTT 

Intercontinental Terminals Corp. 

Intercontinental Terminals Corp. 

LaGloria Oil and Gas 

Louis Dreyfuss 

Marathon Oil 

Marathon Ash. Pet 

Marathon Ashland Petr. LLC 

Marathon Ashland Petroleum 

Mobil Beaumont Ref. 

Mobil Oil Corp. 

Mobil Corp. 

Pakhoed Corp. 

PetroUnited Term. 

Phillips Pet Co. 

Phillips Petroleum 

Phillips Chemical Co. 

Phillips Petroleum 

Shell Chemical Co. 

Solutia Inc. 

Source Environmental Sciences 

Source Environmental Sciences 

Southwest Solvents and Chemicals 

Star Enterprise 

Star Enterprise 

Stolthaven-Houston 

Taback (for API) 

Texas Petrochemicals Corp. 

Ultramar Diamond Shamrock 

Ultramar Diamond Shamrock 

Union Carbide 

Union Carbide 

Email 

pradeep.shetty@fina.com 

mary.logue@fina.com 

kevin.bloomer@fma.com 

mehrau@gatx.com 

stephen.capone@gepex.ge.com 

lon_tullos@huntsman.com 

joelfezzio@imtt.com 

Taas4990swbell.net 

Taas4990swbell.net 

castlbm@ldena.com 

grwilson@marathonoil.com 

wgmoore@mapllc.com 

addelder@mapllc.com 

ktbowden@mapllc.com 

laura_a_dresser@emailjnobil.com 

justin_k_stubbe@emailjnobiI.com 

bill_r_beck@email.mobil.com 

Paktank@pakhoedcorp.com 

stucker@petrounited.com 

saha@bvmex.ppco.com 

drgresh@bvemx.ppco.com 

jmed@ppco.com 

dtemery@bvemx.ppco.com 

srhansen@shellus.com 

paul.w.zawila@solutia.com 

source@pdq.net 

source@pdq.net 

hambone2@flash.net 

raarshor@starentcom 

demetrm@starent.com 

callison@stolt.com 

taback@ix.netcom.com 

jnesser@txpetrochem.com 

marten_mosis@udscorp.com 

allan_griggs@udscorp.com 

neelydm@ucarb.com 

wanedlfilucarb.com _ 

% 
P.10 

ATTACHMENT 2 

°l 
P.11 

7 • *r*i 

Organic Liquids Distribution 

(OLD) NESHAP 

muggguuggi 

£/.£. EPA/Industry Workshop on 

OLD Information Collection Request 

(ICR) 

Exxon Conference Center 

800 Bell Street 

Houston, Texas 

June 3,1998 

*£ \l!k Workshop Agenda 

mmmammMmmmmm 

Registration-8:30 - 9:00 am 

Introduction (Steve Shedd/EPA) - 9:00-9:15 

Review Instructions/Questions — 9:15 -10:15 

• Break-10:15-10:30 

Review Tables/Questions -10:30- 11:30 

• Lunch -11:30 - 12:30 pm 

Question/Answer Session — 12:30 - 1:15 

Workshop Wrap-Up -1:15 - 1:30 

0 
P.12 

M ICR Contacts 

-•m^mTmmtmmMmmtfm<r.rmtimim*nmmmam__i_m 

Steve Shedd- U.S.EPA 

• Telephone: (919)541-5397 

• E-mail: shedd.steve@epa.gov 

• Greg LaFlam/Bernd Haneke — Pacific Environmental 

Services, Inc. 

• Telephone: (919) 941-0333 

• E-mail: glaflam@rtp.pes.com QI bhaneke@rtp.pes.com 

u Updates posted on the TTN Website at: 

. http://www.epa.gov/ttn/oarpg/t3sp.html 

- 0jPV^. • 

?#*•** 

. tf • • 0, 1 

ICR History 

The ICR was developed jointly by the project 

Work Team (U.S. EPA, PES, Inc., and industry 

representatives). 

Trade Groups: API, CMA, ILTA, NACD, NTTC. 

Industry comments and suggestions were 

incorporated into the final version ofthe ICR. 

w 
P.13 

ource Category Description 

Source Category Includes: 

• Storage and transfer of non-gasoline organic liquids 

with hazardous air pollutant (HAP) content. 

• Distribution facilities after the point of custody 

transfer (no oil/natural gas production or processing 

operations). 

a_ 

•.or * ICR Instructions 

-•'•^'''""'pii'''^*'"""^-*^^ jtaiMMJiMfiiiiMH-M 

All responses should be based on Calendar Year 

1997data. 

Responses are due by July 8.1998. 

Note: These slides present a summary for presentation purposes. 

Respondents must follow the complete instructions provided in the 

ICR itself. 

\1" 
P.14 

i-^5 ICR Instructions (2) 

SB 

Two Options for Completing the Survey: 

• Fill out and return the paper copy, using blank 

tables and extra sheets as necessary; OR: 

• Download the electronic version ofthe survey 

on the EPA's TTN website at 

http://www.epa.gov/ttn/oarpg/t3sp.html 

and return paper copy and diskette. 

i&aH I^R Instructions (3) v&i< 

__W_m_m__m____m 

What Size, plants must complete the Survey? 

Plant sites that have actual emissions of 5 tpy 

or greater of a single HAP, or; 

Plant sites that have actual emissions of 12.5 

tpy or greater of a combination of HAP. 

|3 
P.15 

<-*c*r ICR Instructions (4) 

tStKidHf mam "'•^''^-•"•'•*- w***^-" ' 

If a plant site has actual emissions <5 tpy 

of a single HAP; and <12.5 tpy of a 

combination of HAP: 

• The plant site will not have to respond to the 

survey. 

• However, report this finding in writing to the 

EPA. 

> 3{f 1 ICR Instructions (5) 

^^a*^**TM******^*********!*,^^ 

Distribution Operations Include: 

• Incoming and outgoing transfers 

• Storage 

• Associated equipment 

• Waste and wastewater treatment and disposal 

practices 

• Compounding/blending/packaging activities. 

10 

H 
P.16 

, *- - - <N " J 

f \"5 "~ "**-«3 ICR Instructions (6) 

Examples of OLD Facility Types: 

Distribution Terminals (separate) 

Pipeline Facilities 

Compounding/Blending/Packaging Facilities 

Collocated Distribution Facilities 

11 

.y -J?--

, ^ ICR Instructions (7) 

115 ...m 

Organic Liquids to be Surveyed: 

• Organic Liquids with a HAP content of 1,000 

ppmw or greater, AND 

• A True Vapor Pressure of 0.1 psia or greater. 

12 

\ & 

6 
P.17 

. *»,f_i, . ' 

*->•** " /Ci? Instructions (8) 

' z:w»«*mmM U 

Organic Liquid Waste and Wastewater to 

(____•• be Surveyed: 

• Plant sites that generate a total of 0.5 miUion 

gallons per year or more of HAP wastewater 

(excluding segregated stormwater). 

• All semi-aqueous HAP-containing waste 

(sludge) from distribution equipment or 

operations. 

13 

'-•«'.»•* *'-J 

ICR Instructions (9) 

Non-Surveyed Organic Liquids and 

Wastes: 

Must be generally described and quantified. 

A volume throughput for each ofthe nonsurveyed liquids is not required. 

u 

\V 
P.18 

ICR Instructions (10) 

Marine Vessel Operations: 

Marine vessel loading operations subject to the Marine 

Vessel MACT (40 CFR 63, subpart Y) aiejtQLsubject 

to the survey 

Marine tank vessel terminals that only load or unload 

product with HAP content do not have to complete the 

survey; bj__t 

Are subject to the survey if they store HAP-containing 

liquids on site (i.e., in storage vessels). 

15 

ICR Instructions (11) 

mmtmmmm mmimmmmmmmmm mmmmimummmmmmmmmtsmmimmmm 

Marine Tank Vessel operations at plant sites with 

other HAP emission sources must: 

- Show the marine vessel loading operations on a general plot plan: 

• Provide a written description ofthe marine vessel loading 

operations; 

• Fill in the marine vessel loading operation data in wastewater and 

waste Tables 4, 5, and 6. 

• Provide data on each air pollution control device that is not 

dedicated to the marine vessel loading operations (Table 9). 

16 

n 

8 
P.19 

i • _, V**' ICR Instructions (12) 

Information Required for Chemical 

Manufacturing Facility Plant Sites: 

A general plot plan indicating which storage vessels and loading 

arms and racks are regulated under the Hazardous Organic 

NESHAP (HON) or another MACT rule. 

For storage vessels and loading raclcsfor which data are supplied 

in Tables 2 and 3, fill out Table 1, but do not fill out Tables 4-8. 

In Table 2, list the presence (but not the requested data) of all 

distribution storage vessels Ml regulated by another MACT. 

17 

s

 ^» ICR Instructions (13) 

Information Required for Chemical 

FK^H Manufacturing Facility Plant Sites (2): 

• Table 3 (and Table 9 as applicable) for each 

loading rack, arm, or hose that loads surveyed 

liquids and is not assigned to a regulated 

process unit or is not a tank farm rack subject 

to the HON or another MACT. 

18 

l« 
P.20 

ICR Instructions (14) 

Information Required for Petroleum 

Refineries: 

• A plot plan that shows which storage vessels are regulated under 

the Refinery MACT. 

. Table 1 (but not Tables 4-8) must be filled out for storage vessels 

and loading racks for which data are supplied in Tables 2 and 3. 

• Table 2 must list the presence of all distribution storage vessels 

not regulated by another MACT. 

• Table 3 (and Table 9, as applicable) must be filled out for each 

loading rack and arm that loads surveyed liquids other than 

gasoline into tank trucks or railcars. 

19 

ICR Instructions (15) 

tmmtmmtm "-~-*«- * ««ffitfil«M»^ 

Other MACT Standards 

• Final MACT standards discussed in the original 

instructions include: Hazardous Organic NESHAP 

(HON), Gasoline Distribution, Marine Vessel 

Loading, and Refinery MACT. 

• For this survey, respondents may exclude distribution 

storage vessels, loading racks, and loading arms 

clearly regulated under any final or non-final MACT 

but must identify the equipment as follows: 

20 

rt 

10 
P.21 

-*-?,>.•,, ri7'\ 

"** C-" ******* > **i 

> . > . * ; _• 

ICR Instructions (16) 

Other MACT Standards (2): 

. On the plotplan. show which storage vessels and loading arms 

and racks are regulated under a final or non-final MACT, and 

identify the MACT standard on each piece of equipment. Publicly 

available written information must support determinations of nonfinal MACT coverage. 

• "Regulated" vessels, loading arms, and racks can include those 

that are otherwise subject to the MACT, but are not in fact 

controlled because they do not meet the control criteria (small 

tank, etc.) given in the subject MACT. 

21 

ICR Instructions (17) 

_t__s___m__mm___m_M 

Gasoline and Gasoline Operations/Facilities that 

do not need to be surveyed: 

• Bulk Gasoline Terminals and Pipeline 

Facilities that: 

—handle only Gasoline, and/or 

—handle Organic Liquids that qualify 

as non-surveyed liquids. 

22 

^0 

11 
P.22 

ICR Instructions (18) 

_m 

Gasoline and Gasoline Operations at Surveyed Facilities: 

• All gasoline products (including aviation gasoline) must be 

partially surveyed at all facilities that are responding. 

• Provide a brief written description of gasoline operations. 

• Provide gasoline information in the storage, transfer, equipment 

leak, and control equipment sections (Tables 1,2,3,7, and 9) unless 

the equipment is: 

—in dedicated gasoline service, or 

-regulated under the Gasoline Distribution MACT 

23 

ICR Instructions (19) 

•Htt_m_m _____TM_~^r^^^*~_~~.*~~.~.*-.~~u00 . 

Gasoline and Gasoline Operations at Surveyed 

Facilities (2): 

• Equipment in dedicated gasoline service or regulated by the 

Gasoline Distribution or Refinery MACT must be shown on the 

plotplan(s), and generally described as requested 

• Gasoline information must be included in wastewater and waste 

Tables 4,5, and 6. 

24 

l\ 

12 
P.23 

ICR Table Instructions 

Table 1: Organic Liquids Stored or Transferred 

• Enter a name for each HAP containing organic liquid stored or 

unloaded at the OLD facility; 

• Liquid must meet criteria presented in survey; 

. Do not include wastewater; 

• List HAP constituents; 

. For liquids referenced in Table 8, the family name ofthe liquid 

may be used in lieu of listing each mdividual blend. 

25 

ICR Table Instructions (2) 

-v^jjg^^j^^^^^^^g^^^^^^^^^^^^^^S^Si_^_^S^S_mmmBi^BB_. 

_t " ~ 

Table 2: Storage Tanks 

• Enter a unique identifier code (e.g, TOJ or TOO!) for each 

storage tank with greater than 5,000 gallon capacity; 

• List organic liquids from Table 1 stored in each tank during the 

base year; 

• Use the same liquid names/codes from Table 1; 

• For each Add-On Control Device used to control vapor emissions 

from storage tanks, fill out Table 9; 

• Fill out a separate table for each device listed in Table 9. 

2. 

n> 

13 
:^.1 s 

fc_^__| ICR Table Instructions (3) 

Table 3: Transfer Operations 

Enter each loading rack/arm that transfers organic liquids listed 

in Table 1 to tank trucks, railcars, barges, or tanker ships; 

Fill out Table 9 for each control device used to control vapor 

emissions from liquid transfers. 

P.24 

27 

P,rSiiICR Table Instructions (4) 

mmMmmmmmmmmmmmmmu 

S^. TMi\ I able 4: Wastewater Flow and Drain Control 

List the principal sources of wastewater generation from 

distribution activities; 

Use the supplied codes or your own code and description; 

Estimate the annual flow rate from each source; 

Include the HAP constituents and their concentrations in ppmw 

or mg/l. 

28 

^ 3 

14 
P.25 

ICR Table Instructions (5) 

•""•••*''' g^ ^ 

Table 5: Wastewater Collection and Treatment 

Control 

For each wastewater source as listed in Table 4, list the number of 

collection or treatment units applicable to each source; 

Fill out Table 9 for each control device used to control air 

emissions from wastewater. 

29 

ICR Table Instructions (6) 

_m__mmmmm 

Table 6: Semi-Aqueous Waste 

Identify each individual type of waste from distribution activities 

that contains any HAP, and provide information on how the waste 

is collected and treated; 

Fill out Table 9 for each control device used to control air 

emissions; 

Semi-aqueous waste (i.e., sludge) is defined as having between 

10- 90 percent solids. 

30 

•lA 

15 
P.26 

••QuMtek 

ICR Table Instructions (7) 

Table 7: Equipment Leaks 

Leak detection and repair (LDAR) programs involve a formal 

leak survey of equipment components on a fixed schedule (may be 

instrument or visual detection); 

Fill out Table 9 for each control device used to control vapor 

embsions from equipment components. 

31 

:^^ICR Table Instructions (8) 

•mtmmm 

Table 8: Compounding/Blending/Packaging 

Operations 

- This table applies to facilities that mix liquids together to form a 

blend or product; 

• List each separate blend or chemical product name; 

. Families of blended products may be combined into a single entry 

in this table. 

32 

l£ 

16 
P.27 

'•___ ! 

ICR Table Instructions (9) 

Table 9: Air Pollution Control Equipment 

• Complete the applicable section of Table 9 for each air pollution 

control device in use at the OLD facility; 

• F/7/ in the requested parameters, if known; 

• If the parameters are not known identify the presence ofthe device 

by including a table showing the type of device and the emission 

source that it controls; 

• Be specific when listing the emission sources; e.g., Tanks 1,2,3; or 

Loading Racks 1-5, etc. 

33 

ICR Contacts 

p j i >-•mitiriT"ti -'•"'ttnM 

tmmismmmtmma 

Steve Shedd — U.S. EPA 

• Telephone: (919) 541-5397 

• E-mail: shedd.steve@epa.gov 

Greg LaFlam/Bernd Haneke — Pacific Environmental 

Services, Inc. 

• Telephone: (919) 941-0333 

• E-mail: glaflam@rtp.pes.com QL bhaneke@rtp.pes.com 

Updates posted on the TTN Website at. 

• http://www.epa.gov/ttn/oarpg/t3sp.html 

34 

nJ* 

17 
P.28 

ATTACHMENT 3 

S\ 
P.29 

Questions Received and Answered on Notecards at the Organic 

Liquids Distribution Workshop 

1. How did you do such a good job on this survey? 

Answer: The survey integrated industry comments and suggestions. 

* 

2. Does Table 8 (Compounding/Blending/Packaging Operations) have to be completed for 

gasoline terminals because additives are blended? (Additives with HAPs). 

Answer: This issue will be revisited, answer will most likely be posted on EPA's TTN 

website. 

3. Does the ICR cover the loading of HAP containing mixtures that are gaseous at ambient 

temperature? 

Answer: Gases will not be controlled by the Organic Liquids Distribution NESHAP. 

4. Table 8 (Compounding/Blending/Packaging Operations) - If blending occurs in gasoline 

MACT tanks, is information required to be reported on Table 8?: 

Answer: If the tanks are covered by another MACT, then the answer is no. 

5. At a petroleum refinery - tank water draws are routed to the facility-wide wastewater 

collection and treatment system. The specific tank is not subject to the refinery MACT, 

but the wastewater collection and treatment system is subject to the refinery MACT (and 

complies through compliance with the Benzene Waste Operations NESHAP). Do you 

want tank water draw information in the wastewater section ofthe ICR? 

Answer: Yes, but we will not require specific information. 

6. Can you post a document with answers to questions on the Internet? 

Answer: The most pertinent questions and issues will be posted on the TTN website. 

7. Are pressurized liquids (either loaded or unloaded) covered? e.g., vinyl chloride, 

butadiene, methylene chloride. 

Answer: This question will be revisited and answers posted on the TTN website. 

8. Is there any cutoff for loading rack throughput (de minimis)? 

Answer: There is no de minimis cutoff for loading rack throughput. 

1 

03 
P.30 

9. A loading arm handles a HON regulated chemical with controls and non-HON chemicals 

(HAPs) with no controls, (a) Should the non-HON portion be reported here? (b) What if 

they were controlled? 

Answer: (a) Report the non-HON chemicals, (b) Report liquids in the appropriate tables 

and control equipment in Table 9. 

10. Please confirm our understanding that packaging of non-blended or non-compounded 

materials are not included on the survey? 

Answer If they contain HAP, then they must be reported in the survey. 

11. Should ballast water received from marine vessels be included in survey? 

Answer.: Yes, but this issue will be revisited. 

12. Please address the issue of ocean barges - ships 

Ocean barges are configured like ships - have containers the size and shape of ships, 

travel in the ocean like ships. For the purpose ofthis survey, are ocean barges to be 

considered barges or ships? 

Answer: This does not apply to the Organic Liquids Distribution NESHAP. 

13. Can we return an electronic reply converted into Word for windows instead of 

WordPerfect? 

Answer: Yes, return hardcopy and diskette with file. 

14. If a marine loading operation (with tanks) is smaller than the major source threshold 

(10/25 tpy) of subpart Y and is therefore not required to be controlled, does it have to 

complete the ICR? 

Answer: If it has actual emissions greater than the 5/12.5 tpy HAP cutoff, then yes. 

15. Source categories: you say no oil/natural gas production or processing operations are 

included. However, the definition of custody transfer in the proposed Oil and Natural 

Gas Production MACT says custody transfer is the inlet to a natural gas plant, a) Do you 

still intend that we are not to include gas plants? Also, natural gas liquids are often a 

product of natural gas processing; b) are the facilities associated with sales of NGL 

covered? 

Answer: (a). Natural gas plants may potentially be covered by another NESHAP. (b). If 

2 

-2/1 
P.31 

emissions criteria are met and it has emission sources, then yes. 

16. At a Petroleum Refinery, would the following loading and unloading operation be 

included in the survey: Aj_j___: 

solvent loading? (Not subject to HON or MACT) Yes 

propane/LPG into trucks and railcars? No 

diesel No 

asphalt truck loading? Maybe (?) 

product streams that are pipelined out? Maybe (?) 

returned materials (such as off-spec)? Yes(?) 

truck unloading for crude oil? Yes 

17. You have received some excellent questions. Will you, or can you have another, longer 

meeting? 

Answer: The EPA is having a teleconference this Friday (June 5,1998) with the National 

Association of Chemical Distributors. The issue of another meeting is open. 

18. Confirm that a "formal equipment LDAR program" must be one that is required by a 

Federal/State/local rule. 

Answer: This is correct 

19. Confirm that "average" values requested in Table 1 are all annual average values. 

Answer: Yes, use annual averages, but this really depends upon the situation at hand. 

20. Does EPA have authority under Section 114 to require us to prepare marked up plot 

plans? I thought we had to turn over information but didn't have to generate new 

information. 

Answer: The EPA believes that this information is important to the 

NESHAP, and it also believes that it has the authority to request this information. 

21. For a diesel loading rack, the vapors are typically routed to the Vapor Recovery Unit for 

gasoline truck loading even though its not required by state or federal rules. If the VRU 

is shutdown, gasoline loading is stopped, but diesel loading continues. Is this VRU 

considered a control device for diesel loading? 

Answer: Diesel is not a surveyed liquid. 

22. Please confirm our understanding that the survey is to include only "distribution 

tanks...that store organic liquids entering or leaving the plant site (pg. 5: I.E.)" not 

3° 
P.32 

internal transfers, such as temporary storage tanks at the exit of one chemical 

manufacturing process unit and the entrance to another chemical manufacturing process 

unit 

Answer: Process tanks and internal transfers are not covered by this survey. 

23. What definition of "non-gasoline orgamc liquid" or "organic liquid" is being used? Is 

there a regulatory citation for these definitions? 

Answer: A definition may be available in other NESHAPs. 

24. Organic liquids with HAP of 1,000 ppmw are to be surveyed. Is the 1,000 ppmw an 

anrmM average concentration? 

Answ__: For streams that are produced sequentially as different products with 

intentionally different characteristics, consider each stream separately. For streams 

that vary unintentionally over time, use annual average. 

25. Please confirm that "annual average true vapor pressure of at least 0.1 psia" is the sum of 

the partial pressures of HAP only. 

Answer: We are looking for the vapor pressure ofthe liquid, not only ofthe partial 

pressures ofthe HAP. 

26. Please verify that it is not necessary to generate new data to answer the ICR questions. 

Answer: You should not have to generate any new data to answer these IGR questions. 

27. Was the scope of OLD intended to include asphalt emulsion plants or asphalt roofing 

material production plants? These facilities are part of source categories which are listed 

but no MACT standard has been proposed. 

Answer: This will be revisited and posted on the EPA's TTN website. 

28. Page 7, item H lists SIC codes that are exempt: where can we find definitions for these 

codes? They are not in SIC books we possess. 

Answer: This issue has been clarified in the additional instructions which were 

distributed at the meeting. 

29. Please expand on the definition of custody transfer regarding oil/gas operations as it 

pertains to OLD. Is this intended to be any facility after the material is transported from 

the providing operation? 

3\ 
P.33 

Answer: To answer this question, please refer to the E&P MACT. 

30. Background: A refinery receives crude oil by truck. This crude oil is unloaded into 

dedicated tanks at the refinery. The tank is covered by the Refinery MACT. 

Question: Does the survey form need to be completed for the unloading rack? 

Answer Yes, but check the EPA's TTN website for a definitive answer. 

°S~ 
P.34 

Questions Received onNotecards that were Not Answered at the Organic 

Liquids Distribution Workshop 

1. At a petroleum refinery - storage tanks may change service frequently. How should we 

respond for a tank that may be in purely in-process service for a portion of the year and in 

service for distribution-related operations for another portion ofthe year? 

2. Does the ICR cover the unloading of organic liquids from drums into storage (is a 5 5 

gallon drum covered as a container)? 

3. a. Distribution terminals do not track historical incoming vessel types - these are contract 

agreement with customer referencing by mode types which we can list but may not be 

utilized (tank truck, tank car, barge, ship)-can we list them all? 

b. Wastewater generated at marine transfer collected in transfer transport vessels is to be 

reported? The HAP content is not measured. How do you want this reported? 

4. 1,3 Butadiene is handled under pressure and Table 2 does not seem to apply. Do you 

have to complete Table 2 for butadiene? The only emissions are fugitive emissions. 

5. Background: A refinery loading a tank truck from a tank. The tank is covered by the 

refinery MACT. The material being loaded is not gasoline (it is an organic liquid covered 

by the Refinery MACT). 

Question: Does the survey have to be completed for the truck loading rack? 

6. If more than one plant on site, is it okay to fill out separate questionnaire for each plant? 

7. On plot plan, is it ok to identify areas and then attach a list of equipment in each area 

instead of trying to put all the requested infomiation on the plot plans? 

8. Methanol, a HAP, is unloaded from a barge into a storage tank and then goes to a nonHON unit as a raw material, is this covered? 

9. Methylene chloride, a HAP, is unloaded, stored, and used as a solvent in a non-HON 

process unit What part, if any, ofthe unloading is covered by this old survey. 

10. For my refinery, I will be spending more time providing information showing what other 

MACT standards apply (Refinery, HON, Gas Distribution, Marine Loading, MACTs). 

Why can't I provide only the information concerning the equipment affected by this 

MACT ICR. (Loading operations, tankage, etc. for the diesel, jet, fuel oil, naphtha, etc. 

that is nol covered by the existing MACTs). 

33 
P.35 

* rt 

9 

11. What about loading spent caustic (with HAPs and vapor pressure) for reprocessing? Is it 

in survey? 

12. If materials are loaded or unloaded directly to/from tank and no loading rack is involved 

and tank is subject to MACT, is it exempt from the survey because it is not a rack? 

13. Asphalt may have HAPs and vapor pressure (at loading temperature) to meet criteria, but 

becomes solid at room temp. Is it included in survey? 

14. If unloaded with or without rack in MACT facilities why do you need it to be in survey? 

(e.g., crude, feedstacks) 

15. Hexane tank is used for purpose. Hexane is a carrier or solvent for each process. Hexane 

doesn't become part ofthe product, it is simply circulated. Does it qualify as MACT? 

16. Gasoline additives - organic, containing HAPs - are brought in and stored on site in the 

supplier's tank. These additives are used in gasoline blends. Are the additive tanks 

covered and need to be reported? Is the piping to the blender covered? 

17. Typical carrier is xylene or similar boiling range solvent. V.P. are typically 0.01-0.2 

from 0-100 °F additive emission from 10,000 gallon (?) tanks are 5-50 lb/yr VOC. All 

terminals I will have to report on will be 99.9% exempt or MACT covered except for 

additive. This whole process is being driven by 200 lbs/yr VOC at 25 sites. A waste of 

your time and mine. 

18. Please explain the philosophy of gathering information that is not part of this standard 

development As far as what controls are in place (such as HON), the other standards can 

be directly referenced. 

19. Liquid has total HAP above 1,000 ppm then report - any de minimis report? For 

example, liquid has 900 ppm by 200 ppm xylene and 1 ppm ethylbenzene do we report 

ethyl benzene? 

20. Why do you need to know split between employees and contractors? This is extraneous, 

and could *ary over time. 

21. There is enough confusion to warrant an additional 30 days to deal with this ICR. Will 

you consider a September 3 due date? 

22. I'm still confused about just what a "co-located old distribution facility" is. Can you give 

some real world examples for refineries and chemical plants? 

^ 
P.36 

23. The materials seem to use the terms "plant" and "facility" interchangeably. Is that your 

intent? 

24. It was my understanding based on a call to EPA that minor sources (<10 or 25 tons/yr) do 

not have to respond to this survey. Is that right? It seems that since the MACT standards 

affect major sources, that data from minor sources are not relevant. 

25. What is the definition of an organic liquid? What about a stream that is 60% water, 40% 

methanol? Is 51% water an aqueous material rather than organic liquid? 

26. Gasoline distribution terminal that also distributes diesel. The gasoline distribution 

MACT covers the loading rack and the wastewater which is also impacted by the diesel. 

The air pollution control (VRU or VCU) was put in place to meet the gas MACT. Would 

this have to be Usted in this survey? 

27. Example of RCRA issue on Table 6: EPA is expected to soon list crude oil tank btms as a 

RCRA hazardous waste. This means that once it is "generated" (i.e., removed from tank), 

it is subjected to the various RCRA handling and processing regulations. Among these 

are AA, BB, and CC (subparts of parts 264 and 265) which regulate air emissions. I 

expect you would find no value in our including these wastes on Table 6 response. 

Similarly, most or all ofthe following have RCRA status: O/w separator sludges, 

biosludges, contaminated soil, sewer/sump sludges, t/e water drains (Table 5). I'd suggest 

excluding RCRA-regulated wastes from Table 5/6 responses. 

28. A loading rack is the source, however, a particular arm is dedicated to a non-gasoline 

product One product may be OLD, do we only include info for the arms and not the 

complete source? 

29. Table 1, IH HAP Constituents - with MSDS's used to provide the HAP speciation, is it ok 

to provide a range of HAP concentrations? 

30. Our only source of wastewater is a drip collection drain located under a loading rack. It 

is lined up to wastewater treatment. The flowrate and concentration are TOTALLY 

variable, depending on the condition ofthe tank car and the amount of rainfall. How do I 

report a wastestream concentration and flowrate? 

31. Will any additional QA documents be put on the internet? 

32. Are intemal pipelines or tank car/trucks transfers within a site covered? (Plant to plant or 

unit to unit within an integrated facility(site)). 

3 $